POLICIES & COMPLAINT RESOLUTION

IPC Investment Corporation

IPC Investment Corporation has procedures in place to handle any written or verbal complaint received in a fair and prompt manner. This is a summary of those procedures, which we provide to new clients, clients who have filed a complaint and that we also make available on our website at www.ipcc.ca.

IPC Investment Corporation's ("IPCIC") Policy is to request that all complaints be filed in writing. There may be instances where IPCIC receives a verbal complaint from a client which will warrant the same treatment as a written complaint. However, unless it is totally impractical or there are other compelling reasons not to, clients will normally be advised that we will require their complaint in writing before we can proceed any further. For confidentiality reasons, we will only deal with the client or another individual who has the client’s express written authorization to deal with us.

How to Contact the Compliance Department: Your concern and supporting documents which will be of assistance to us in reviewing your concerns can be submitted by the following methods:

We acknowledge complaints promptly, generally within 5 business days. Within the acknowledgement, you will be provided the name and contact information of the Complaints & Investigations Officer responsible for handling the complaint as well as a copy of the Mutual Fund Dealers Association (MFDA) Client Complaint Information form.

Assessing the Complaint: The Complaints & Investigations Officer will conduct a factual investigation and analysis of the matters specific to the complaint. In order to accomplish this, we will gather information including a written response from your Representative addressing the issues raised in the complaint, copies of documentation completed and any other documentation which may be available (notes, e-mails). The Complaints & Investigations Officer will review all documentation as well as the comments of both the client and representative to assess the merits of the complaint. Additional analysis may be necessary, dependant on the nature of the complaint.

Conclusion: Once the investigation has been completed, a written summary of the investigation which addresses your concerns will be prepared and forwarded you within 90 calendar days. In the event that additional time is required, you will be notified in writing and provided with both an explanation as to why our response has been delayed along with our best estimate of the time required for completion of our response. If you are dissatisfied with our examination of your complaint or the outcome of the examination, you may respond to our letter indicating the issues which you feel were not addressed. We will respond to communications you send us after our response to the extent necessary to implement a resolution or to address any new issues or information you provide. You may also refer to the MFDA Client Complaint Information form which will be included with the response. This form provides guidance regarding the options available to you should you wish to pursue the matter further and includes guidance on the statutes of limitations.

Note: As mutual fund values are not guaranteed, IPCIC cannot assist clients who have experienced losses due to market fluctuations within suitable investments. Our policy is to review the suitability of the investments in comparison to the clients stated risk tolerance and investment objectives.

IPC Securities Corporation

IPC Securities Corporation has procedures in place to handle any written or verbal complaint received in a fair and prompt manner. This is a summary of those procedures, which we provide to new clients, clients who have filed a complaint and that we also make available on our website at www.ipcc.ca.

IPC Securities Corporation’s (“IPCSC”) Policy is to request that all complaints be filed in writing. There may be instances where IPCSC receives a verbal complaint from a client which will warrant the same treatment as a written complaint. However, unless it is totally impractical or there are other compelling reasons not to, clients will normally be advised that we will require their complaint in writing before we can proceed any further. For confidentiality reasons, we will only deal with the client or another individual who has the client’s express written authorization to deal with us. IPCSC has appointed its Chief Compliance Officer (CCO) as its Designated Complaints Officer.

How to Contact the Designated Complaints Officer: Your concern and supporting documents which will be of assistance to us in reviewing your concerns can be submitted by the following methods:

We acknowledge complaints promptly, generally within 5 business days. Within the acknowledgement, you will be provided the name and contact information of the Complaints & Investigations Officer responsible for handling the complaint as well as a copy of An Investor’s Guide to Making a Complaint.

Assessing the Complaint: The Complaints & Investigations Officer will conduct a factual investigation and analysis of the matters specific to the complaint. In order to accomplish this, we will gather information including a written response from your Advisor addressing the issues raised in the complaint, copies of documentation completed and any other documentation which may be available (notes, e-mails). The Complaints & Investigations Officer will review all documentation as well as the comments of both the client and Advisor to assess the merits of the complaint. Additional analysis may be necessary, dependent on the nature of the complaint.

Conclusion: Once the investigation has been completed, a written summary of the investigation which addresses your concerns will be prepared and forwarded you within 90 calendar days. In the event that additional time is required, you will be notified in writing and provided with both an explanation as to why our response has been delayed along with our best estimate of the time required for completion of our response.

If you are dissatisfied with our examination of your complaint or the outcome of the examination, you may respond to our letter indicating the issues which you feel were not addressed. We will respond to communications you send us after our response to the extent necessary to implement a resolution or to address any new issues or information you provide. You may also refer to the Investor’s Guide to Making a Complaint brochure which will be included with the response. This brochure provides guidance regarding the options available to you should you wish to pursue the matter further and includes guidance on the statutes of limitations.

Note: IPCSC cannot assist clients who have experienced losses due to market fluctuations within suitable investments. Our policy is to review the suitability of the investments in comparison to the clients stated risk tolerance and investment objectives.

IPC Estate Services

Any client who submits a complaint to IPC Estate Services Inc. (“IPCES”) will be treated with respect and dignity and their complaint will be dealt with in good faith. As a general recommendation, we advise clients who have concerns regarding their accounts to contact their Representative to determine if their concern can be easily addressed. If you have a concern which you believe has not been adequately addressed by your Representative or your concern is regarding your Representative or your Representative has been unable to resolve your complaint satisfactorily, you can contact the Compliance Department at IPC Estate Services Inc.

IPCES Policy is to request that all complaints be filed in writing. There may be instances where IPCES receives a verbal complaint from a client which will warrant the same treatment as a written complaint. However, unless it is totally impractical or there are other compelling reasons not to, clients will normally be advised that we will require their complaint in writing before we can proceed any further.

How to Contact the Compliance Department: Your concern and supporting documents which will be of assistance to us in reviewing your concerns can be submitted by the following methods:

In accordance with our Complaint Handling Policy, the Compliance Department will acknowledge receipt of your complaint within 5 business days. Within the acknowledgement, you will be provided the name and contact information of the Compliance Officer responsible for handling the complaint as well as a copy of the Financial Services Commission of Ontario (FSCO) Complaint Summary form.

Assessing the Complaint: The Compliance Department will conduct a factual investigation and analysis of the matters specific to the complaint. In order to accomplish this, we will gather information including a written response from your Representative addressing the issues raised in the complaint, copies of documentation completed and any other documentation which may be available (notes, e-mails). A Compliance Officer will review all documentation as well as the comments of both the client and representative to assess the merits of the complaint. Additional analysis may be necessary, dependant on the nature of the complaint.

Conclusion: Once the investigation has been completed, a written summary of the investigation which addresses the clients concerns will be prepared and forwarded to the client. Generally this will be completed within 4-6 weeks. In the event that additional time is required, you will be notified in writing.

If you are dissatisfied with our examination of your complaint or the outcome of the examination, you may respond to our letter indicating the issues which you feel were not addressed.

The normal avenues available to you as a client, following the steps noted below are as follows:

Contact the Insurance Carrier that issued your policy if you have questions regarding your insurance contract. The contact information should be noted on your contract.

Contact the Insurance ombudsman who works for the Financial Services Commission of Ontario (FSCO) or similar provincial regulator depending upon your province of residence to review your concerns.

Note: Our policy is to review the sales process of the insurance contract that was sold to you by your Insurance Advisor. The Insurance Carrier that issued your policy will also review the sales process of your advisor and the information supplied by you to allow them to underwrite your insurance contract.

STATEMENT OF POLICIES

IPC Investment Corporation

STATEMENT OF POLICIES

Conflicts of Interest

Securities laws of Canada require securities dealers and other registrants to take reasonable steps to identify existing material conflicts of interest and material conflicts of interest that the registrant in its reasonable opinion would expect to arise between the registrant, including an individual acting on behalf of the registrant, and a client. In addition, when a registrant trades in or advises with respect to their own securities or securities of certain other issuers to which they or certain other parties related to them, are related or connected, they are required to provide particular disclosure to the client.

These rules require dealers and advisers, prior to trading with or advising their customers or clients, to inform them of the relevant relationships and connections with the issuer of the securities.

To maintain public confidence and respect, IPC Investment Corporation (IPCIC) has adopted policies and procedures to assist in identifying and minimizing any conflicts of interest that IPCIC may face.

A. General

Under certain circumstances, IPCIC may deal with you or for you in securities transactions where the issuer of those securities or the other party to the transaction is IPCIC or a party having an ownership or business relationship with IPCIC. Since these transactions may create a conflict between IPCIC’s interest and yours, IPCIC is required by securities law to disclose to you certain relevant matters relating to the transactions. This statement contains a general description of the required disclosure.

B. Important Concepts

"Connected Issuer” – A connected issuer means an issuer or selling securityholder distributing securities where the issuer or selling securityholder, or a related issuer of the issuer or selling securityholder, has a relationship with any of the following persons or companies that may lead a reasonable prospective purchaser of the securities to question if IPCIC and the issuer are independent of each other for the distribution:

(a) IPCIC;

(b) a related issuer of IPCIC;

(c) a director, officer or partner of IPCIC; or

(d) a director, officer or partner of a related issuer of IPCIC.

“Influential Securityholder” – Generally includes a securityholder that exercises influence over an issuer on the basis of direct or indirect ownership of securities aggregating more than 20% of the voting rights or entitlements to distributions of an issuer (or more than 10% if accompanied by the entitlement to nominate at least 20% of a board of directors).

“Related Issuer” – A person or company is a related issuer to IPCIC if:

(a) the person or company issuing securities is an influential security holder of IPCIC;

(b) IPCIC is an influential security holder of the person or company issuing securities; or

(c) IPCIC, and the person or company issuing securities, are a related issuer of the same third person or company.

Attached to this statement is a list of Related Issuers and Connected Issuers of IPCIC together with a concise statement of the relationship between them and IPCIC.

C. Disclosure

Where IPCIC acts as your dealer or advises you with respect to securities issued by IPCIC or by a Related Issuer or, in the course of distribution, by a Connected Issuer IPCIC must disclose the nature and extent of its relationship with the issuer of the securities, or that IPCIC is the issuer. IPCIC will also disclose to you where IPCIC knows or should know that, if as a result of IPCIC acting as your dealer or adviser, securities will be purchased from or sold to IPCIC, a Related Issuer or, in the course of distribution, from a Connected Issuer.

The following is a list of the time and manner in which these disclosures will be made:

(a) Where IPCIC buys or sells securities for your account, the required disclosure will be contained in the trade confirmation and [monthly] account statement which [we prepare and send] are sent to you;

(b) Where IPCIC advises you with respect to the purchase or sale of securities, the disclosure must be made prior to the giving of the advice, either through the receipt of this disclosure or otherwise; or

(c) Where IPCIC underwrites securities, the required disclosure will be contained in the prospectus or other document being used to qualify those securities.

IPCIC may, from time to time, be deemed to be related or connected to one or more issuers for purposes of this disclosure and other rules of the securities laws. IPCIC may have acted, and is prepared to continue to act, where permitted by law, as an adviser, dealer or underwriter with respect to securities of such Related and Connected Issuers and to provide the full range of services customarily provided by IPCIC in respect of securities of other issuers. IPCIC shall carry out such services in the ordinary course of its business in accordance with our usual practices and procedures and in accordance with all applicable disclosure and other regulatory requirements.

D. Revision or Amendment

Revisions or amendments to this statement will be provided to each client periodically. An up to date version of this statement is available on request from the Compliance Department as specified below.

DISCLOSURE OF RELATED ISSUERS AND CONNECTED ISSUERS

The following is a list as of August 17, 2017 of issuers that are Related Issuers or Connected Issuers to IPCIC by virtue of the ownership of equity interests, directly or indirectly, by affiliates or subsidiaries of Power Financial Corporation. Only Connected Issuers who offer their securities in Canada are included in the following list of Related and Connected Issuers.

Power Corporation of Canada

Groupe Bruxelles Lambert S.A.

Bellus Health Inc.

Pargesa Holdings S.A.

Imerys S.A.

GP Strategies Corp.

Great-West Lifeco Inc.

Great-West Lifeco Finance (Delaware) LP

Great-West Lifeco Finance (Delaware) LP II

The Canada Life Assurance Company

Canada Life Capital Trust

IGM Financial Inc.

Investors Group Trust Co. Ltd.

Investors Syndicate Limited

Mackenzie Mutual Funds

Mackenzie Exchange Traded Funds

Laurentian Bank Mutual Funds

Investors Group Mutual Funds

Counsel Mutual Funds

Quadrus Mutual Funds

Mackenzie Master Limited Partnership

Setanta Constituted Unit Trusts

Putnam Canadian Fixed Income Global Alpha Fund

Putnam Fixed Income Opportunities Fund, Ltd.

Howson Tattersall Pool Funds

Investment Planning Counsel Inc.

Mackenzie Global Large Cap Quality Growth Pooled Fund

DISCLOSURE OF RELATED REGISTRANTS

In addition, IPCIC wishes to advise its clients if it has any principal shareholders, officers, partners or directors who are also principal shareholders, officers, partners or directors of another securities registrant or another entity that, but for a registration exemption, would be required to be a securities registrant and to provide details of the policies and procedures adopted to minimize the potential for conflict of interest resulting from these relationships.

As of August 17, 2017, each of the following Related Registrants is a direct or indirect subsidiary of Power Financial Corporation (“PWF”).

Related Registrants Registered in Canada

(individually, a “Related Registrant”)

Canada Life Asset Management Limited

Counsel Portfolio Services Inc.

IPC Investment Corporation

IPC Securities Corporation

Mackenzie Financial Corporation

Investors Group Securities Inc.

Investors Group Financial Services Inc.

I.G. Investment Management, Ltd.

Quadrus Investment Services Ltd.

GLC Asset Management Group Ltd.

Setanta Asset Management Limited

Putnam Investments Canada ULC

PanAgora Asset Management, Inc.

WealthSimple Inc.

Canadian ShareOwner Investments Inc.

Excel Private Wealth Inc.

In addition, Related Registrants may include other dealers and advisers which become subsidiaries of PWF.

A Related Registrant may from time to time have directors and/or officers who are also directors and/or officers of another Related Registrant.

Each of PWF and the Related Registrants is a separate legal entity that generally carries on its business independently. However, a Related Registrant may enter into arrangements with another Related Registrant respecting such matters as the provision of support services, distribution or products and services, and client referrals.

Conflicts of interest resulting from the above relationships are minimized in a number of ways. Regulations, policies and procedures made by the industry regulating bodies restrict, and otherwise regulate the relationships among dealers, advisers and Related Registrants and govern their relationships with one another and clients. As well, each Related Registrant has its own conflict of interest policies. Compliance with both internal and external regulations, policies and procedures are monitored at all levels of the company under the guidance of IPCIC Compliance Department.

In addition to the foregoing, officers and employees of each Related Registrant are subject to Codes of Conduct governing their actions and internal compliance policies and procedures.

For further information concerning these matters, please contact the Compliance Department:

IPC Securities Corporation

STATEMENT OF POLICIES

Conflicts of Interest

Securities laws of Canada require securities dealers and other registrants to take reasonable steps to identify existing material conflicts of interest and material conflicts of interest that the registrant in its reasonable opinion would expect to arise between the registrant, including an individual acting on behalf of the registrant, and a client. In addition, when a registrant trades in or advises with respect to their own securities or securities of certain other issuers to which they or certain other parties related to them, are related or connected, they are required to provide particular disclosure to the client. These rules require dealers and advisers, prior to trading with or advising their customers or clients, to inform them of the relevant relationships and connections with the issuer of the securities.

To maintain public confidence and respect, IPC Securities Corporation (IPCSC) has adopted policies and procedures to assist in identifying and minimizing any conflicts of interest that IPCSC may face.

A. GeneralUnder certain circumstances, IPCSC may deal with you or for you in securities transactions where the issuer of those securities or the other party to the transaction is IPCSC or a party having an ownership or business relationship with IPCSC. Since these transactions may create a conflict between IPCSC’s interest and yours, IPCSC is required by securities law to disclose to you certain relevant matters relating to the transactions. This statement contains a general description of the required disclosure.

B. Important Concepts

"Connected Issuer” –A connected issuer means an issuer or selling securityholder distributing securities where the issuer or selling securityholder, or a related issuer of the issuer or selling securityholder, has a relationship with any of the following persons or companies that may lead a reasonable prospective purchaser of the securities to question if IPCSC and the issuer are independent of each other for the distribution:

(a) IPCSC;

(b) a related issuer of IPCSC;

(c) a director, officer or partner of IPCSC; or

(d) a director, officer or partner of a related issuer of IPCSC.

“Influential Securityholder” – Generally includes a securityholder that exercises influence over an issuer on the basis of direct or indirect ownership of securities aggregating more than 20% of the voting rights or entitlements to distributions of an issuer (or more than 10% if accompanied by the entitlement to nominate at least 20% of a board of directors).

“Related Issuer” – A person or company is a related issuer to IPCSC if:

(a) the person or company issuing securities is an influential security holder of IPCSC;

(b) IPCSC is an influential security holder of the person or company issuing securities; or

(c) IPCSC, and the person or company issuing securities, are a related issuer of the same third person or company.

Attached to this statement is a list of Related Issuers and Connected Issuers of IPCSC together with a concise statement of the relationship between them and IPCSC.

C. Disclosure

Where IPCSC acts as your dealer or advises you with respect to securities issued by IPCSC or by a Related Issuer or, in the course of distribution, by a Connected Issuer IPCSC must disclose the nature and extent of its relationship with the issuer of the securities, or that IPCSC is the issuer. IPCSC will also disclose to you where IPCSC knows or should know that, if as a result of IPCSC acting as your dealer or adviser, securities will be purchased from or sold to IPCSC, a Related Issuer or, in the course of distribution, from a Connected Issuer.

The following is a list of the time and manner in which these disclosures will be made:

(a) Where IPCSC buys or sells securities for your account, the required disclosure will be contained in the trade confirmation and [monthly] account statement which [we prepare and send] are sent to you;

(b) Where IPCSC advises you with respect to the purchase or sale of securities, the disclosure must be made prior to the giving of the advice, either through the receipt of this disclosure or otherwise; or

(c) Where IPCSC underwrites securities, the required disclosure will be contained in the prospectus or other document being used to qualify those securities.

IPCSC may, from time to time, be deemed to be related or connected to one or more issuers for purposes of this disclosure and other rules of the securities laws. IPCSC may have acted, and is prepared to continue to act, where permitted by law, as an adviser, dealer or underwriter with respect to securities of such Related and Connected Issuers and to provide the full range of services customarily provided by IPCSC in respect of securities of other issuers. IPCSC shall carry out such services in the ordinary course of its business in accordance with our usual practices and procedures and in accordance with all applicable disclosure and other regulatory requirements.

D. Revision or Amendment

Revisions or amendments to this statement will be provided to each client periodically. An up to date version of this statement is available on request from the Compliance Department as specified below.

DISCLOSURE OF RELATED ISSUERS AND CONNECTED ISSUERS

The following is a list as of August 17, 2017, of issuers that are Related Issuers or Connected Issuers to IPCSC by virtue of the ownership of equity interests, directly or indirectly, by affiliates or subsidiaries of Power Financial Corporation. Only Connected Issuers who offer their securities in Canada are included in the following list of Related and Connected Issuers.

Power Corporation of Canada

Groupe Bruxelles Lambert S.A.

Bellus Health Inc.

Pargesa Holdings S.A.

Imerys S.A.

GP Strategies Corp.

Great-West Lifeco Inc.

Great-West Lifeco Finance (Delaware) LP

Great-West Lifeco Finance (Delaware) LP II

The Canada Life Assurance Company

Canada Life Capital Trust

IGM Financial Inc.

Investors Group Trust Co. Ltd.

Investors Syndicate Limited

Mackenzie Mutual Funds

Mackenzie Exchange Traded Funds

Laurentian Bank Mutual Funds

Investors Group Mutual Funds

Counsel Mutual Funds

Quadrus Mutual Funds

Mackenzie Master Limited Partnership

Setanta Constituted Unit Trusts

Putnam Canadian Fixed Income Global Alpha Fund

Putnam Fixed Income Opportunities Fund, Ltd.

Howson Tattersall Pool Funds

Investment Planning Counsel Inc.

Mackenzie Global Large Cap Quality Growth Pooled Fund

DISCLOSURE OF RELATED REGISTRANTS

In addition, IPCSC wishes to advise its clients if it has any principal shareholders, officers, partners or directors who are also principal shareholders, officers, partners or directors of another securities registrant or another entity that, but for a registration exemption, would be required to be a securities registrant and to provide details of the policies and procedures adopted to minimize the potential for conflict of interest resulting from these relationships. As of August 17, 2017, each of the following Related Registrants is a direct or indirect subsidiary of Power Financial Corporation (“PWF”).

Related Registrants Registered in Canada

(individually, a “Related Registrant”)

Canada Life Asset Management Limited

Counsel Portfolio Services Inc.

IPC Investment Corporation

IPC Securities Corporation

Mackenzie Financial Corporation

Investors Group Securities Inc.

Investors Group Financial Services Inc.

I.G. Investment Management, Ltd.

Quadrus Investment Services Ltd.

GLC Asset Management Group Ltd.

Setanta Asset Management Limited

Putnam Investments Canada ULC

PanAgora Asset Management, Inc.

WealthSimple Inc.

Canadian ShareOwner Investments Inc.

Excel Private Wealth Inc.

In addition, Related Registrants may include other dealers and advisers which become subsidiaries of PWF.

A Related Registrant may from time to time have directors and/or officers who are also directors and/or officers of another Related Registrant.

Each of PWF and the Related Registrants is a separate legal entity that generally carries on its business independently. However, a Related Registrant may enter into arrangements with another Related Registrant respecting such matters as the provision of support services, distribution or products and services, and client referrals.

Conflicts of interest resulting from the above relationships are minimized in a number of ways. Regulations, policies and procedures made by the industry regulating bodies restrict, and otherwise regulate the relationships among dealers, advisers and Related Registrants and govern their relationships with one another and clients. As well, each Related Registrant has its own conflict of interest policies. Compliance with both internal and external regulations, policies and procedures are monitored at all levels of the company under the guidance of IPCSC Compliance Department.

In addition to the foregoing, officers and employees of each Related Registrant are subject to Codes of Conduct governing their actions and internal compliance policies and procedures.

For further information concerning these matters, please contact the Compliance Department: